Owen Equipment & Erection Co. v. Kroger

437 U.S. 365

 

RULE:

A finding that federal and nonfederal claims arise from a common nucleus of operative fact, does not end the inquiry into whether a federal court has power to hear the nonfederal claims along with the federal ones. Beyond this constitutional minimum, there must be an examination of the posture in which the nonfederal claim is asserted and of the specific statute that confers jurisdiction over the federal claim, in order to determine whether Congress has expressly or by implication negated the exercise of jurisdiction over the particular nonfederal claim.

FACTS:

Respondent widow filed a wrongful-death action against a power company. The power company filed a third-party complaint against petitioner equipment company. Summary judgment was granted for the power company, and the case went to trial between the widow and the equipment company. The equipment company appealed the United States Court of Appeals for the Eighth Circuit's affirmation of the district court's denial of its motion to dismiss.

ISSUE:

Did the district court have power to entertain respondent's lawsuit against petitioner as a third-party defendant based on diversity jurisdiction?

ANSWER:

No.

CONCLUSION:

The Court reversed the judgment of the court of appeals. The Court held that it was undisputed that there was no independent basis of federal jurisdiction over the widow's state-law tort action against the equipment company because both were citizens of Iowa. Thus, it was clear that the widow could not originally have brought suit in federal court naming the equipment company and the power company as codefendants, because citizens of Iowa would have been on both sides of the litigation. The widow's claim against the equipment company, however, was entirely separate from her original claim against the power company, where the equipment company's liability to the widow depended not at all upon whether or not the power company was also liable. The nonfederal claim was asserted by the widow, who voluntarily chose to bring suit upon a state-law claim in a federal court. The Court held that the district court lacked power to entertain the widow's lawsuit against the equipment company. Thus, the asserted inequity in the equipment company's alleged concealment of its citizenship was irrelevant.

Click here to view the full text case and earn your Daily Research Points.